Like Bonnie Tyler, NRC is Holding Out for a HERO

In Nuclear Energy Activist Toolkit #47, I summarized the regulations and practices developed to handle emergencies at nuclear power plants. While that commentary primarily focused on the response at the stricken plant site, it did mention that nuclear workers are required to notify the Nuclear Regulatory Commission (NRC) promptly following any declaration of an emergency condition. The NRC staffs its Operations Center 24 hours a day, 365 days a year to receive and process emergency notifications.

In late September 2017, I was made aware that the NRC was not staffing its Operations Center with the number of qualified individuals as mandated by its procedures. Specifically, NRC Management Directive 8.2, “Incident Response Program,” dictates that the Operations Center be staffed with at least two individuals: one qualified as a Headquarters Operations Officer (HOO) and one qualified as a Headquarters Emergency Response Officer (HERO). The HOO is primarily responsible for responding to a nuclear plant emergency while the HERO provides administrative support such as interagency communications.

I learned that the NRC Operations Center was instead often being staffed with only one person qualified as a HOO and a second person tasked with a “life support” role. In other words, the “life support” person would summon help in case the HOO keeled over from a heart attack or spilt hot coffee on sensitive body parts.

I wrote to Bernard Stapleton, who heads the NRC’s incident response effort, on October 3, 2017, inquiring about the Operations Center staffing levels. The NRC’s response was both rapid and thorough.

A conference call was conducted on October 12, 2017, between me and Steve West, Acting Director of the NRC’s Office of Nuclear Security and Incident Response, and members of his staff, Bern Stapleton and Bo Pham. They informed me that it had been a challenge for the agency to staff the Operations Center in summer and fall 2017 with qualified HEROs due to several watch standers taking other positions within the NRC and a temporary hiring freeze imposed after the unanticipated termination of the construction of two new reactors at the Summer nuclear plant in South Carolina.

The former reason made sense as individuals with these skills seek promotions. The latter reason made sense as the NRC sought to find new positions for its staff members formerly assigned to the Summer project. The one-two punch of qualified persons leaving and the replacement pipeline being temporary shut off prevented the Operations Center from always being staffed with an individual HERO qualified. The Operations Center always had a HOO; it sometimes lacked a HERO.

They told me that two persons had recently been hired to fill the empty positions on the Operations Center staffing chart and those new hires would be undergoing training to achieve HERO qualifications. In addition, they told me about initiatives to qualify NRC staff outside of the Operations Center section to provide a larger cushion against future staffing challenges. The larger pool of qualified watch standers would have the collateral benefit of expanding the skill sets of individuals not assigned full-time to the Operations Center.

The NRC followed up on the conference call by sending me a letter dated November 16, 2017, documenting our conversation.

UCS Perspective

It would be better for everyone if the NRC had always been able to staff its Operations Center with individuals qualified as HOOs and HEROs. But the downside from problem-free conditions is the challenge in determining whether they are due more to luck than skill. How an organization responds to problems often provides more meaningful insights than a period of problem-free performance. On the other hand, an organization really, really good at responding to problems might reflect way too much experience having problems.

In this case, the NRC did not attempt to downplay or excuse the Operations Center staffing problems. Instead, they explained how the problems came about, what measures were being taken in the interim period, and what steps were planned to resolve the matter in the long term.

In other words, the NRC skillfully responded to the bad luck that had left the Operations Center short-handed for a while.

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Johanna

…and if you did not contact them, they would still need a HERO or two.

Matt Mallet

The implication of this article is that the HERO would play a critical role in the response to an emergency condition at an operating nuclear power plant and we should be concerned that this “watch station” was not always manned. I will observe there didn’t appear to be an adverse consequence of the lack of the NRC staffing this position at all times in the recent past. This provides some evidence (not conclusive) that an on-station hero is not necessary. Good science (and economics) always involves considering plausible alternatives, which in this case would not be hiring more personnel( at tax-payer expense) but eliminating the requirement for the on-station HERO position.